APPLIES TO All Employers with DC Employees EFFECTIVE December 28, 2018 QUESTIONS? Contact HR On-Call (888) 378-2456 In Browning-Ferris Industries v. NLRB, the D.C. Circuit Court stated that the National Labor Relations Board’s (NLRB) standards of “right to control” and “indirect control” are appropriate factors to determine joint-employer status on a fact-based, case-by-case basis.